FEDERAL ELECTION COMMISSIONWASHINGION. D C 20463

"HIS IS TIE IEGI,NII OF MIJR #

DTE FIL!ED CA tW.

CAMERMN

/ f 0.

m

0 w.Mnu rugn.-4Wy

FEDERAL ELECTION COMMISSIONWASHIoCIN. DC M%*3

June 23, 1988

TO: LAWRENCE 14. NOBLEGENERAL COUN,

THROUGH: JOHN C. SUfNB/

1

STAFF DIRE

FROM: OHN D. GIBS ,NOO"AS-SISTANT SiiAF DIRECTOR

REPORTS AN YSIS DIVISION

SUBJECT: REFERRAL O APRIL QUARTERLY NON-FILER UNAUTHORIZEDCOMMITTEES

Attached, for referral to your office, are seven (7)unauthorized committees that failed to file the 1988 AprilQuarterly Report

In accordance with Standard 3 of the 1987-1988 RADReview and Referral Procedures for Unauthorized Comittees, thismatter requires further examination by your office.

All seven committees were sent prior notice of the due date

of the report on March 22, 1988 and were sent Non-Filer Noticeson May 6, 1988 (see Attachments 1 and 2).

Included in this document is a chart which lists each

committee in alphabetical order along with the address and nameof treas.urer, any contacts with the committees, responses and/orreports filed by the committee and the attachment number wherethe items can be located within the document.

If you have any questions, please contact Lisa J. Stolaruk

at 376-2480.

Attachments

COMMtgs Kavolved in 1$85-6iS 6/2S7-19S8 Z2ictlos CYCle OC0lifezrals

1.

2.

3.

1.

2.

3.

4.

5.

" 6. 88NF-28 United Virginia Bankshares Responsible GovernmentFund (C00214965)

- 7.

r

$r)fl ?~

CONhITTEE ID, MANS AND ADDlESSCONTACTSWITH FILER ATCH

a r~lupwolw ....

00000000

I

I

000

eo0 0oo o

CWTCTLEIlTH VILEtRCOMMITTEE ID, NAME AND ADDRESS ATCH

poe 2

IEPORISIE*l'It351093I35 .

.. .. .. .. .. .. .. .. .. .. .. . . .. . 0 0 0 a0 a0 aa0 0 & 0 0 aa a a 0 *0 00o 0 aa *a aa 0 a0 a 0 a

C00214965UNITED VIRGINIA BANKSHARES RESPONSIBLE GOVERNMENT FUND*TREASURER'S NAME: J THOMAS VAUGHAN919 EAST MAIN STREETRICHMOND VA 23219

Telecon

S/31/8-d

*The comittee's name is listed on the Sumry Page of the 1987 Year End and 190 April Iuerterly Upnrts as Cretar Flul) Cm

... overmot .Fand. .3k. iO*stln..tver. has aw.cerive4 am.emmded .SUN0t g,lUttM Jds*MJ6 LSW.9A *.Wi aDm

Letter filed 8/9/8

Rpr filer1 4/

* *QUARTURLY .....

REPORT NOTICEFDERL EECTION COMMSON

S ~m "rtb 22. 1966

--- --April guszterly 01/0l/N -3/1/S6 04/15/66 04/15/86

PAMI cMm M= PACs-Ii 1e) filing on a quarterly

report is AWpri.

baIZ A D f Di Airnxbasis mast file their next

All fia ial ativity (not pceviously reported) that occred daringthe reporting period..

Party oaittees and PACe use Pe1 3 (enclosed).

Consult the instructions an the back of the roc 3 Summary Page.Note state filing requiremets also.

Cinittees should affix the pel-off label from the envelope to Line 1of the report. Corrections should be made on the label.

in-waczc m m sCoiittees which make contributions or expenditures (includingindependent expenditures) in connection with a candidate's prinaryelection maust also file a 12-day Pre-Election Report if the activitywas not previously reported. See the January Record.

Comittees which ake an independent expenditure of $1,000 or ore,after the 20th day, but more than 24 hours before an election, mustreport it within 24 bours.

TASUUI OW POLITICAL COISTflT An USPOWIBZ FOR VILUG ALLmOles an TI. /hILUB TO DO so is SDJZCT TO sW -- ACTION.

COS UITIS IXG ILLIGIDLI WX S R WING NOI-PC rONS W L BEMQCIW TO M 0Z

*Reports sent by registered or certified mail must be postmarked bythe sailing date. Otberwise, they must be received by the filingdate.*Fron the date of registration, of the close of books of the lastreport filed, whichever is later.

IR IS TMI, Call: 202/376-3120 or 800/424-9530

5--

Identificati

Reference: J

Dear TREASUNJ

It hasCommission (violation ofreferenced Inotified pre

It is ithe Federal20463 (or wiSenate, as iportions shcequivalent S

Althougenforcementand a letter

If youtoll-free nus2480.

Se ATTAH3MMN 2

FEDERAL ELECTION COMMISS1ONWASHINGTON. D.C. 20M3 MQin7

May 6. 1988

SIP

)n Number: IX

Lpril Quarterly Report (1/1/88-3/31/88)

II:

come to the attention of the Federal Elec["the Comission6) that your committee may be

2 U.S.C. §434(a) for failing to file the aReport of Receipts and Disbursements. Youriously of the due date for this report.

mportant that you fVie this report immediatelyElection Commission, 99 E Street, NW, WashingtonLth the Clerk of thk House or the Secretary ofappropriate). A copy of the report or the releuld also be filed with the Secretary of Statetate officer. See 2 U.S.C. 5439.

I the Commission may initiate an audit or 1action concerning this matter, your prompt respof explanation will be taken into consideration.

have any questions, please contact ANALYST onmber (800) 424-9530. Our local number is (202)

Sincerely,

John D. GibsonAssistant Staff DirectorReports Analysis Division

tionin

bovewere

with•DCthe

vantor

egalonse

our376-

United Virginia Bankshares ResponsibleGovernment Fund (C00214965)

(Attachments 8a - d)

n - 4'L4 7 3 0n-3 0

rEDERAL ELECTION COMMISSION MATN 16JUN331997-1955

COMMITTI INDEX 01 DISCLOSUIE DOCUNMNTS - (0 PAN 2

COMMITTEE DOCUNINT RICEIPTS DIsIUeRSNINTS* U NIIC ICOVEAl SIE lrS

FIIIII I~l I II I I IIII I Ilt~llIt PS 6ltln5 1 'l lll33l

UNITED VIRGINIA DANKNARS RESPONSIBLE GOVERNMENT FUND" CONNECTED ORGANIZATION: UNITED VIRGINIA BANKSHARES INC

1987 STATEMENT O ORGANIZATIONMID-YEAR REPORT 17,YEAR-END 50tYEAR-END - ANINDMINT 50,IQUEST I01 ADDITIONAL INIORMATIONREQUEST 1OR ADDITIONAL INIOIATION 2ND

1966 MIICILLANEOUS NOTICE FROM PICMISCILLANIOUS REPORT TO PECMIICILLANIOUI REPOT TO ICAPRIL QUARTERLYNOTICE O FAILURE TO FILEJULY QUARTERLY 14v

TOTAL

491636636

021,65421,654

7,900

1.I25

0 41v579

200

292

62,619

13 IC00114U5 NON-t l ISLWtlIS~*14MAY674 3-t hIC#&?WM

IJANS? -21U18W is 4

LlowY 1"sf1UIS - I I

UAW 204A 4:

II4 21" -tSUlAN. I1AiB -aliwCm S2

9mI ISASUlUPS -11I 19 i

IJIl0 Tom-

All reports have been reviewed.

Ending cash-on-hand balance as of 5/31/88: $41,042

Debts and obligations owed by the counittee as of 5/31/88: $0

*Attachme nt Sb0'

Ia"UN TOCUSSTIII:

SUTACT:

SATIE,

ANALY/ST:

SUSECT:

THE FIES:Un|td Vtusoinia Rankecha,, nt Rbttnt4hm Ma AU~lesnt Vmd

J. Thm Vauan -- s

1v 31988 ,Ar .

Robrt R. Di ardn. ..

1988 Ant11 (iartanlv .pnr

mOQO mOf m mOM o mpdw am m - - -

I called Mr. Vaughan at 4:05 P.M. ir. Vaughan was not

available, so I left a message that the Comission had not received his

contittee's 1988 April Quarterly Report, and to call me back if he had any

questions. The secretary said the report was mailed, and that she would give

fi. Vaughan the message.

J Vhomas *t.qwn

June. . 1D I 9

.Up. John D. GdbMAsuistant Staff OdevcorRepor. Analysis DMectorFtderal Election Li•mmiedaIt@ ngton, D.C. 2040

Dear .r. Gibsmw

i respune 1o )UW 8*110r of Jne & W Mew bM m CM it r- Nro NWOb. telephone on tvo %PeMgm , first w uilud m wem rwm tenecessity to file 'lere Db m e yeq I YO M 10i beue IOU heft melection .var, that we/el foli qIndtwly. Oa fmid miU to Mr. INuao,o., for clarification of o 17 yUear fi1 O 1 he m queoned.

The crorected er-ewd, ApIl 14 eud JuN Ifth mpaits wIll be mt to Vorattention by June 14. ISM. I m wry swry for Oh nwwwrd -,-- and Oemi.qwer.,ta ding regdng he fiNngs.

Sincerel%

J. Thomas Vaughen, TreasaurwCrestar Re.ponsible Government Fund

cc: .%',r. Robert B. DoNardoReport.s Analyst

0pCw

fQ

cc~w Saab Attachment 8c

is.. g !A1 2ut-)..6t

$M; 0 If a" - I - I T:' ,'d 4 f I fA I

. ,: ,Iro V,,9-," .1 f8,4rk

U

U-

P~h

6,

C,

C,

?VFW, W@

g'gU '&smm

IJof# a s# f li at.w hWM 1s9iI, g ."o -~ .Ba

t . Ca oS~0d0%w,".S~

.c~ C,8RSC.05 'om'w I) . $ 20.005 20.0

cc~ s 0mas'uOU10 VAN C3e1" 4"gs Pu

161 s ms %own an A Wi SY W Cw Ug NO-

mse,.a~~~COa A~cs.agUus S Noe 4mC*"--S P900 eaan.wPuS El T' 1. kg? Ot my rwWkilojuW e Uftuvu IWTftsUdD

o.~~ ~~ .~~ .j . . gq . q .i S ~ v 369273.90 ~ 2 SC O3

mtr.-~~ ~ ~ ~ ~ ~ AS ' 61W -C OMA&

r3 "#I : L:0IMDUAL 3L3CIN COUMZSSION L': O.

999" Streete nW.Washington, D.C. 20463

£flhIUt~Uf I N Y 3

3310?= 1TvtFRZ'ST so~lU COMBLes KZOMT

PAD Referral 88NF 23-29Staff Member: Susan Beard

RNAL LY GEN ERAT E D

RESIONDENTS:

United Virginia Bankshares Responsible GovernmentFund and J. Thomas Vaughan, as treasurer

RELEVANT STATUTES: 2 U.S.C. 5 432(e)(5)2 U.S.C. S 433(c)2 U.S.C. 5 434(a)(4)(A)(i)

INTERNAL REPORTS CHECKED: Referral Materials

FEDERAL AGENCIES CHECKED: None

I. GENERATION OF RATTER

The Reports Analysis Division ("RAD") referred the above

seven-committees to the Office of the General Counsel on

June 23, 1988. The basis for the attached referral is the

committees' failure to file the 1988 April Quarterly Report or to

do so in a timely fashion.

mO

F.

-2-

1. I FACTALM AND LGAL ANALYSIS

A. Filing of Reports

The Federal Election Campaign Act of 1971, as amended ("the

Act"), provides that for unauthorized committees filing

quarterly, such committees shall file quarterly reports, in a

calendar year in which a regularly scheduled general election is

held. 2 U.S.C. I 434(a)(4)(A)(i). Quarterly Reports are to be

filed no later than the 15th day after the last day of each

calendar quarter. Thus, the due date for the 1988 April

Quarterly Report was April 15, 1988. The following committees

did not file the 1988 April Quarterly Report by this date:

Name of Committee Date Report Filed

United Virginia Bankshares June 14, 1988Responsible Government Fund

0 --3-

-5-

The R D Referral Materials indicate that United Virginia

Sankshares Responsible Government Fund listed its name as

*Crestar Financial Corporation Responsible Government Fund" on

its 1987 Year End and 1988 April Quar'erly Reports. An amended

Statement of Organization indicating a change in the Committee's

name or the connected organization's name has not been received.

Accordingly, the office of the General Counsel recommends

that the Commission find reason to believe that United Virginia

Bankshares Responsible Government Fund and J. Thomas Vaughan, as

treasurer, violated 2 U.S.C. 5 432(e)(5).

Z. DISCUSSION OF COUCILIA2I0U AM CIVIL P33LLTT

49i

IIz z. RECORmaK TIOS

1.

2.

3. Open Matters Under Review with respect to the followingcommittees and find reason to believe the followingcommittees and their treasurers violated 2 U.S.C.5 434(a)(4)(A)(i):

a.

b.

C.

d. United Virginia Bankshares Responsible GovernmentFund and J. Thomas Vaughan, as treasurer; and,

-10-

4.

5. Find reason to believe ,hat United Virginia BanksharesResponsible Government Fund and 3. Thomas Vaughan, astreasurer, violated 2 U.S.C. S 432(e)(5).

6.

7.

8. Enter into conciliation with the following committees-and their treasurers prior to a finding of probablecause to believe:

a.

b.

C.

d. United Virginia Bankshares Responsible GovernmentFund and 3. Thomas Vaughan, as treasurer; and,

e.

9. Approve the attached letters, factual and legalanalyses, and proposed conciliation agreements to therespective committees listed in recommendation 8.

Lawrence M. NobleGeneral Counsel

BY:Lois G. LernerAssociate GeneraZunsel

Attachments1. Referral Materials2. Proposed Conciliation Agreements (5),

Letters (5), and Factual and Legal Analyses (5)

-.j 0/ lAgoeDUO - f #'-

31OR .FEDERAL ELECTION COMMISSION

Zn the Matter of

United Virginia Bankshares ResponsibleGovernment Fund and J. Thomas Vaughan,

as treasurer

) PAD Ref. 88NF 23-29

))))

CERTIFICATION

I, Marjorie W. Emmons, Secretary of the Federal Election

Commission, do hereby certify that on July 27, 1988, the

Commission decided by a vote of 5-1 to take the following

actions in RAD Ref. 88NF 23-29:

1.

(Continued)

____________________ - ~ -~ ~ ~ ~

Page 2ri.

2.

3. Open Matters Under Review with respect to the following

committees and find reason to believe the following

committees and their treasurers violated 2 U.S.C.S 434(a) (4) (A) (i):

a.

b.

C.

d. United Virginia Bankshares Responsible GovernmentFund and J. Thomas Vaughan, as treasurer; and,

e.

4.

5. Find reason to believe that United Virginia Bankshares

Responsible Government Fund and J. Thomas Vaughan, as

treasurer, violated 2 U.S.C. S 432(e) (5).

'I.

Federal zection Comm i0onCertification for RAD Ref. 88NF23-29

July 27, 1988

m

rodoal Election com~mTIon Page 3cetftilcation forR D Ref. setIP23-29July 27, 1988

8. Enter into conciliation with the following committeesand their treasurers prior to a finding of probablecause to believe:

a.

b.

C.

d. United Virginia Bankshares Responsible GovernmentFund and J. Thomas Vaughan, as treasurer; and,

e.

9. Approve the letters, factual and legal analyses, andproposed conciliation agreements to the respectivecommittees listed in action 8 above.

Commissioners Aikens, Elliott, Josefiak, McDonald,

McGarry, and Thomas voted affirmatively for the decision.

Attest:

Date garjorie W. EmmonsSecretary of the Commission

Received in the Office of Commission Secretary:Thurs.,Circulated on 48 hour tally basis: Fri.,Deadline for vote: Tues.,

JMcF.

7-21-88, 4:007-22-88, 12:007-27-88, 4:00

I A'I- 9 - ?-4 ?-

FEDERAL ELECTION COMMISSIONWASHINGTON, D C. 20463

August 2, 1988

J. Thomas VaughanUnited Virginia Bankshares ResponsibleGovernment Fund

919 East main StreetRichmond, VA 23219

RE: MUR 2661United Virginia BanksharesResponsible GovernmentFund and J. ThomasVaughan, as treasurer

Dear Mr. Vaughan:

;On July 27 , 1968, the Federal Election Commission found thatthere is reason to believe United Virginia Bankshares ResponsibleGovernment Fund (OCommittee") and you, as treasurer, violated2 U.S.C. 5S 432(e)(5) and 434(a)(4)(A)(i), provisions of theFederal Election Campaign Act of 1971, as amended ("the Act").The Factual and Legal Analysis, which formed a basis for theCommission's finding, is attached for your information.

Under the Act, you have an opportunity to demonstrate that noaction should be taken against the Committee and you, asItreasurer. You may submit any factual or legal materials thatyou believe are relevant to the Commission's consideration ofthis matter. Please submit such materials to the GeneralCounsel's Office within 15 days of your receipt of this letter.Where appropriate, statements should be submitted under oath.

In the absence of any additional information demonstratingthat no further action should be taken against the Committee andyou, as treasurer, the Commission may find probable cause tobelieve that a violation has occurred and proceed withconciliation.

In order to expedite the resolution of this matter, theCommission has also decided to offer to enter into negotiationsdirectbd towards reaching a conciliation agreement in settlementof this matter prior to a finding of probable cause to believe.Enclosed is a conciliation agreement that the Commission hasapproved.

If you are interested in expediting the resolution of thismatter by pursuing preprobable cause conciliation and if youagree with the provisions of the enclosed agreement, please signand return the agreement, along with the civil penalty, to the

J. Thomas VaughanPage 2

Comission. In light of the fact that conciliation negotiations,prior to a finding of probable cause to believe, are limited to amaximum of 30 days, you should respond to this notification assoon as possible.

Requests for extensions of time will not be routinelygranted. Requests must be made in writing at least five daysprior to the due date of the response and specific good causemust be demonstrated. in addition, the office of the GeneralCounsel ordinarily will not give extensions beyond 20 days.if you intend to be represented by counsel in this matter,please advise the Commission by completing the enclosed formstating the name, address, and telephone number of such counsel,and authorizing such counsel to receive any notifications and

other communications from the Commission.This matter will remain confidential in accordance with2 U.S.C. 55 437g(a)(4)(B) and 437g(a)(12)(A), unless you notifythe Commission in writing that you wish the investigation to bemade public.

For your information, we have attached a brief description ofthe Commission's procedures for handling possible violations ofthe Act. If you have any questions, please contact MichaelMarinelli, the attorney assigned to this matter, at (202)376-8200.

Sincerely,

Thomas J. osefiakChairman

EnclosuresFactual and Legal AnalysisProceduresDesignation of Counsel FormConciliation Agreement

FEDERL ELECTION COKISSON

FACTUAL AND LEGAL ANLYSIS

RESPONDENTS: United Virginia Bankshares RUR 2661Responsible Government Fundand J. Thomas Vaughan, astreasurer

The Federal Election Campaign Act of 1971, as amended ("the

Act"), provides that for unauthorized committees filing

quarterly, such committees shall file quarterly reports, in a

calendar year in which a regularly scheduled general election is

held. 2 U.S.C. S 434(a)(4)(A)(i). Quarterly Reports are to be

filed no later than the 15th day after the last day of each

calendar quarter. Thus, the due date for the 1988 April

Quarterly Report was April 15, 1988. The committee, however, did

not file the 1988 April Quarterly Report by April 15, 1988.

Accordingly, there is reason to believe the committee and its

treasurer have violated 2 U.S.C. S 434(a)(4)(A)(i).

The Act also provides that the name of any separate

segregated fund established pursuant to Section 441b(b) shall

include the name of its connected organization. 2 U.S.C.

S 432(e)(5). The committee has listed its name as "Crestar

Financial Corporation Responsible Government Fund" on its reports

since the 1987 Year End Report. An amended Statement of

Organization indicating a change in the committee's name or the

connected organization's name has not been filed with the

Commission.

Accordingly, there is reason to believe that the committee

and its treasurer have violated 2 U.S.C. S 432(e)(5).

Crestar Bank I919 East Main StreetP 0 Box 26665RHi.hmond, Virginia 23261-6665W0i()4) 782-7906

e~CC~337FFEIAL E IN C"OMMiSSIOt

hAIO OO i

88 SEP -8 AH 8 59

J. Thomas VaughanSenior Vice President andCorporate Government Relations Officer

September 1, 1988

Mr. George F. RishelAssistant General CounselFederal Election CommissionWashington, D.C. 20463

RE: MUR 2661United Virginia BanksharesResponsible GovernmentFund and J. ThomasVaughan, as Treasurer

Dear Mr. Rishel:

Enclosed is the signed Conciliation Agreement and our check for $600.00.

I appreciate your assistance and consideration and apologize for the

inconvenience this matter has caused the Commission. We will make every

effort to assure that future filings are made on time.

Sincerely,

J. Thomas Vaughan

sds

Enclosure

Formerly United Virginia Bank

j~rSOAR

r r

rn

".0 _ .

o Co~;4 -

r4

BEFORE THE FEDERAL ELECTION CONRISSION

In the matter of

United Virginia Bankshares Responsible )Government Fund and J. Thomas Vaughan, )as treasurer )

NUR 2661

GENERAL COUNSEL'S REPORT

* SEmVEDOT 04

I * BACKGROUND

Attached is a conciliation agreement which has been signed

by J. Thomas Vaughan, the treasurer of United Virginia Bankshares

Responsible Government Fund (the "Committee").

On July 27, 1988, the Commission found reason to believe

that the Committee had violated 2 U.S.C. SS 432(e)(5) and

434(a)(4)(A)(i) by failing to timely file its 1988 April

Quarterly Report and failing to amend its Statement of

Organization to reflect a change in the name of its connected

organization.

In accordance with the provisions of the conciliation

-2-

agreement on August 17, 1988, the Committee amended its Statement

of Organization to change the Committee's name from United

Virginia Bankshares Responsible Government Fund to Crestar

Financial Corporation Responsible Government Fund.

IT. RECORRlND&TKOng

1. Accept the attached conciliation agreement with UnitedVirginia Bankshares Responsible Government Fund andJ. Thomas Vaughan, as treasurer.

2. Close the file

3. Approve the attached letter.

Lawrence M. Noble0) General Counsel

/BY:Date Lois G. Letter

Associate General Counsel

Attachments1. Committee response2. Conciliation Agreement

V" 3. Photocopy of civil penalty check4. Letter to Respondent

Staff Assigned: Michael Marinelli

FEDERAL ELECTION COMMISSIONWASHINGTON, D C 20463

MEMORANDUM

TO:

FROM:

DATE:

SUBJECT:

LAWRENCE M. NOBLEGENERAL COUNSEL

MARJORIE W. EMMONS/CANDACE M. JONESt$%

COMMISSION SECRETARY

September 27, 1988

Objection to MUR 2661 - General Counsel's ReportSigned September 22, 1988

The above-captioned document was circulated to the

Commission on Monday, September.6, 1988 at 11:00 A.M.

Objection(s) have been received from the Commissioner(s)

as indicated by the name(s) checked below:

Commissioner

Commissioner

Commissioner

Commissioner

Commissioner

Commissioner

Aikens

Elliott

Josefiak

McDonald

McGarry

Thomas

This matter will be placed on the meeting agenda

for Tuesday, October 4, 1988

Please notify us who will represent your Division before the

Commission on this matter.

xx

BEFORE THE FEDERAL ELECTION COMMISSION

In the Matter of ))United Virginia Bankshares Responsible )Government Fund and J. Thomas Vaughan, )as treasurer )

MUR 2661

CERTIF ICATION

I, Marjorie W. Emmons, recording secretary for the

Federal Election Commission executive session of October 4,

1988, do hereby certify that the Commission decided by a

vote of 6-0 to return the September 22, 1988 report on

MUR 2661 to the Office of General Counsel in order that a

report can be submitted with the amended conciliation agree-

ment.

Commissioners Aikens, Elliott, Josefiak, McDonald,

McGarry, and Thomas voted affirmatively for the decision.

Attest:

Marjorie W. EmmonsSecretary of the Commission

Date

. %,, ,TTV 75?T"77717'77W' 71 7 7

FEDERAL ELECTION COMMISSIONWASHING ION. I) C 2"13

October 12, 1988

J. Thomas Vaughan, TreasurerUnited Virginia Bankshares Responsible

Government Fund919 East Main StreetRichmond, VA 23219

RE: MUR NUR 2661United Virginia BanksharesResponsible GovernmentFund and J. ThomasVaughan, as treasurer

Dear Mr. Vaughan:

Enclosed is the corrected conciliation agreement.As per conversation with staff from this office, the signedconciliation agreement will be brought before the Commission fora final vote with the office of the General Counseltsrecommendation for approval.

If you have any questions, please contact Michael Marinelli,the attorney assigned to this matter, at (202) 376-8200.

Sincerely,

Lawrence M. NobleGeneral Counsel

BY: Lois G. LernerAssociate General Counsel

EnclosureConciliation Agreement

BEFORE THE FEDERAL ELECTION CONNISSION

In the matter of )MUR 2661

United Virginia Bankshares Responsible )Government Fund and J. Thomas Vaughan, )as treasurer )

CONCILIATION AGREEMENT

This matter was initiated by the Federal Election Commission

("Commission"), pursuant to information ascertained in the normal

course of carrying out its supervisory responsibilities. The

Commission found reason to believe that United Virginia

Bankshares Responsible Government Fund and J. Thomas Vaughan, as

treasurer, ("Respondents") violated 2 U.S.C. 55 432(e)(5) and

434(a)(4)(A)(i).

NOW, THEREFORE, the Commission and the respondents, having

participated in informal methods of conciliation, prior to a

finding of probable cause to believe, do hereby agree as follows:

I. The Commission has jurisdiction over the Respondents and

the subject matter of this proceeding, and this agreement has the

effect of an agreement entered pursuant to 2 U.S.C.

5 437g(a)(4)(A)(i).

II. Respondents have had a reasonable opportunity to

demonstrate that no action should be taken in this matter.

III. Respondents enter voluntarily into this agreement with

the Commission.

IV. The pertinent facts in this matter are as follows:

1. United Virginia Bankshares Responsible Government

@0 -2-

Fund is a political committee within the meaning of 2 U.S.C.

S 431(4).

2. J. Thomas Vaughan is the treasurer of United

Virginia Bankshares Responsible Government Fund.

3. Section 434(a)(4)(A)(i) of Title 2 provides that

unauthorized committees filing quarterly shall file quarterly

reports in a calendar year in which a regularly scheduled

election is held. Quarterly reports are to be filed no latter

than the 15th day after the last day of each calendar quarter.

4. Respondents were required to file the 1988 April

Quarterly Report no later than April 15, 1988. Respondents did

not file the 1988 April Quarterly Report until June 14, 1988,

disclosing receipts of $200 and disbursements of $7,900.

5. Section 432(e)(5) of Title 2 provides that the name

of any separate segregated fund established pursuant to

Section 441b(b) shall include the name of its connected

organization.

6. Respondents have not filed an Amended Statement of

Organization indicating a change in Respondents' name or its

connected organization's name.

V. 1. Respondents failed to file the 1988 April Quarterly

Report in a timely fashion in violation of

2 U.S.C. 5 434(a)(4)(A)(i).

2. Respondents' name does not contain the name of

Respondents' connected organization in violation of 2 U.S.C.

S 432(e)(5).

VI. 1. Respondents will pay a civil penalty to the Federal

-3- 0Election Commission in the amount of six hundred dollars

($600.00), pursuant to 2 U.S.C. S 437g(a)(5)(A).

2. Respondents will file an Amended Statement of

Organization indicating a change in Respondents' name or the name

of Respondents, connected organization.

VII. The Commission, on request of anyone filing a complaint

under 2 U.S.C. S 437g(a)(l) concerning the matters at issue

herein or on its own motion, may review compliance with this

agreement. If the Commission believes that this agreement or any

requirement thereof has been violated, it may institute a civil

action for relief in the United States District Court for the

District of Columbia.

VIII. This agreement shall become effective as of the date

that all parties hereto executed same and the Commission has

approved the entire agreement.

IX. Respondents shall have no more than 30 days from the

date this agreement becomes effective to comply with and

implement the requirements contained in this agreement and to so

notify the Commission.

X. This Conciliation Agreement constitutes the entire

agreement between the parties on the matters raised herein, and

no other statement, promise, or agreement, either written or

-4-

oral, made by either party or by agents of either party, that is

not contained in this written agreement shall be enforceable.

FOR THE COMMISSION:

Lawrence M. NobleGeneral Counsel

BY:Lois G. LernerAssociate General Counsel

Date

FOR THE RESPONDENTS:

(Name)(Position)

Date

0

FEDERAL ELECTION COMMISSIONWASNWECON. oC is

THZS is ?NZ ZND OF MUR * Zorp CV/

0v crv- •

88 OV "2 A1111O SS

BEFORE THE FEDERAL ELECTION CONISSION

In the Ratter of)RUR 2661

United Virginia Bankshares Responsible )Government Fund and 3. Thomas Vaughan, )as treasurer )

GENERAL COUNSZL'S REPORT

I. 'BACKGROUND

Attached is a conciliation agreement which has been signed

by J. Thomas Vaughan, the treasurer of United Virginia Bankshares

Responsible Government Fund (the wCommittee").

On July 27, 1988, the Commission found reason to believe

that the Committee had violated 2 U.S.C. SS 432(e)(5) and

434(a)(4)(A)(i) by failing to timely file its 1988 April

Quarterly Report and failing to amend its Statement of

Organization to reflect a change in the name of its connected

organization.

In accordance with the provisions of the conciliation

agreement on August 17, 1988t the Committee amended its Statement

of Organization to change the Committee's name from United

Virginia Bankshares Responsible Government Fund to Crestar0

Financial Corporation Responsible Government Fund.

C II. RECORRENDATIOUS

i. Accept the attached conciliation agreement with UnitedVirginia Bankshares Responsible Government Fund and3. Thomas Vaughan, as treasurer.

2. Close the file

3. Approve the attached letter.

Lawrence H. NobleGeneral Counsel

_ _ _ _ _ _ _ _ _ _ _ _ _ (BY:

Date oVGLreAssocii te General Counsel

Attachments1. Committee response2. Conciliation Agreement3. Photocopy of civil penalty check4. Letter to Respondent

Staff Assigned: Michael Marinelli

BEFORE THE FEDERAL ELECTION COMMISSION

In the Matter of

United Virginia Bankshares ResponsibleGovernment Fund and J. Thomas Vaughan,as treasurer

CERTIFICATION

I, Marjorie W. Emmons, Secretary of the Federal

Election Commission, do hereby certify that on November 4,

1988, the Commission decided by a vote of 6-0 to take

the following actions in MUR 2661:

1. Accept the conciliation agreement with UnitedVirginia Bankshares Responsible GovernmentFund and J. Thomas Vaughan, as treasurer, asrecommended in the General Counsel's reportsigned November 1, 1988.

2. Close the file.

3. Approve the letter, as recommended in theGeneral Counsel's report signed November 1,1988.

Commissioners Aikens, Elliott, Josefiak, McDonald,

McGarry, and Thomas voted affirmatively for the decision.

Attest:

Date rtr of EmonsSecretary of the Commission

Received in the Office of Commission Secretary:Wed.,Circulated on 48 hour tally basis: Wed.,Deadline for vote: Fri.,

11-2-88,11-2-88,11-4-88,

MUR 2661

10:554:004:00

FEDERAL ELECTION COMMISSIONWASHN;E ON. 6 ,3 November 10, 1988

CERTIFIED NAILRETURN RECEIPT REQUESTED

J. Thomas Vaughan, TreasurerUnited Virginia Bankshares ResponsibleGovernment Fund

919 East Main StreetRichmond, VA 23219

RE: NUR 2661United Virginia BanksharesResponsible GovernmentFund and J. ThomasVaughan, as treasurer

Dear Mr. Vaughan:

On November 4 , 1988, the Federal Election Commission

c accepted the signed conciliation agreement and civil penaltysubmitted on your behalf in settlement of a violation of 2 U.S.C.5 432(e)(5) and 434(a)(4)(A)(i), provisions of the FederalElection Campaign Act of 1971, as amended. Accordingly, the filehas been closed in this matter. This matter will become a partof the public record within 30 days. If you wish to submit anyfactual or legal materials to appear on the public record, pleasedo so within ten days. Such materials should be sent to theOffice of the General Counsel.

Please be advised that information derived in connection withany conciliation attempt will not become public without thewritten consent of the respondent and the Commission. See2 U.S.C. 5 437g(a)(4)(B). The enclosed conciliation agreement,however, will become a part of the public record.

J. Thomas VaughanPage 2

Enclosed you will find a copy of the fully executedconciliation agresent for your files. If you have any

questions, please contact Michael Marinelli, the attorneyassigned to this matter, at (202) 376-8200.

Sincerely,

Lawrence M. NobleGeneral Counsel

BY: Lois G. LernerAssociate General Counsel

EnclosureConciliation Agreement

RECfIVEO RE WED';'RA1rF, t FEDERAL I}EC 104'JMN, S~

880CT 19 AlO 17 88OCT 19 A" 99 12

BEFORE TUE FEDERAL ELECTION CONIION

In the matter of )) UR 2661

United Virginia Bankshares Responsible )Government Fund and 3. Thomas Vaughan, )as treasurer )

CONCILIATION AGREERENT

This matter was initiated by the Federal Election Commission

("Commission"), pursuant to information ascertained in the normal

course of carrying out its supervisory responsibilities. The

Commission found reason to believe that United Virginia

Bankshares Responsible Government Fund and 3. Thomas Vaughan, as

C treasurer, ("Respondents") violated 2 U.S.C. 55 432(e)(5) and

434(a)(4)(A)(i).

NOW, THEREFORE, the Commission and the respondents, having

participated in informal methods of conciliation, prior to a

finding of probable cause to believe, do hereby agree as follows:

I. The Commission has jurisdiction over the Respondents and

the subject matter of this proceeding, and this agreement has the

effect of an agreement entered pursuant to 2 U.S.C.

S 437g(a)(4)(A)(i).

II. Respondents have had a reasonable opportunity to

demonstrate that no action should be taken in this matter.

III. Respondents enter voluntarily into this agreement with

the Commission.

IV. The pertinent facts in this matter are as follows:

1. United Virginia Bankshares Responsible Government

Fund is a political committee within the meaning of 2 U.8C,

S 431(4).

2. J. Thomas Vaughan is the treasurer of United

Virginia Bankshares Responsible Government Fund.

3. Section 434(a)(4)(A)(i) of Title 2 provides that

unauthorized committees filing quarterly shall file quarterly

reports in a calendar year in which a regularly scheduled

election is held. Quarterly reports are to be filed no latter

than the 15th day after the last day of each calendar quarter.

4. Respondents were required to file the 1988 April,fl

Quarterly Report no later than April 15, 1988. Respondents did

cnot file the 1988 April Quarterly Report until June 14, 1988,

disclosing receipts of $200 and disbursements of $7,900.

5. Section 432(e)(5) of Title 2 provides that the name

of any separate segregated fund established pursuant to

Section 441b(b) shall include the name of its connected

organization.

6. Respondents have not filed an Amended Statement of

cc Organization indicating a change in Respondents' name or its

connected organization's name.

V. 1. Respondents failed to file the 1988 April Quarterly

Report in a timely fashion in violation of

2 U.S.C. 5 434(a)(4)(A)(i).

2. Respondents' name does not contain the name of

Respondents' connected organization in violation of 2 U.S.C.

5 432(e)(5).

VI. 1. Respondents will pay a civil penalty to the Federal

-3-

Blection Commission in the amount of six hundred dollars

($600.00), pursuant to 2 U.S.C. I 437g(a)(5)(A).

2. Respondents will file an Amended Statement of

Otganization indicating a change in Respondents' name or the name

of Respondents' connected organization.

VII. The Commission, on request of anyone filing a complaint

under 2 U.S.C. S 437g(a)(1) concerning the matters at issue

herein or on its own motion, may review compliance with this

agreement. If the Commission believes that this agreement or any

requirement thereof has been violated, it may institute a civil

action for relief in the United States District Court for the

District of Columbia.

VIII. This agreement shall become effective as of the date

that all parties hereto executed same and the Commission has

approved the entire agreement.

IX. Respondents shall have no more than 30 days from the

date this agreement becomes effective to comply with and

implement the requirements contained in this agreement and to so

notify the Commission.

X. This Conciliation Agreement constitutes the entire

agreement between the parties on the matters raised herein, and

no other statement, promise, or agreement, either written or

oral, made by either party or by *9e,0t0 of either party, that is

not contained in this written agr**ma-t shall be enforceable.

FOR THE COMMISSION:

Lawrence M. NobleGeneral Counsel

BY:

Associa e General CounselDate1

FOR THE RESPONDENTS:

10-17-88Datea me

(position) Treasurer

0 *FEDERAL ELECTION COMMISSIONWASHINGTON. D.C. 20463

THIS IS ThE E FPIR# .. .#

DA11E FILMED CAERA ND. _YA5'Z

/ -2